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ARTICLE · 24 JULY 2025

New Exit Tax Rules For Investment Shares

Flick Gocke Schaumburg
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The legal amendment was introduced by the Bundesrat and supplemented by the Finance Committee in its proposed resolution in the Annual Tax Act. Its goal is to provide greater legal certainty and close tax loopholes...

GermanyTax
Michal Fabian Kuhn
Michal Fabian Kuhn
Florian Lindermann
Florian Lindermann

The Annual Tax Act 2024 shall extend how an asset's increase in value is taxed under Sec. 6 of Germany's Foreign Tax Act (the Außensteuergesetz). One of its key measures is the extension of exit tax provisions to include certain cases, such as investment shares and shares in special investment funds under Germany's Investment Tax Act (the Investmentsteuergesetz). Entered into the draft bill and adopted by the Bundestag (Germany's Federal Parliament) on 18 October 2024, it is likely to receive approval from the Bundesrat (Germany's Federal Council) in November.

Closing tax loopholes

The legal amendment was introduced by the Bundesrat and supplemented by the Finance Committee in its proposed resolution in the Annual Tax Act. Its goal is to provide greater legal certainty and close tax loopholes. Shares held by private individuals in an investment fund or special investment fund with the legal form of a 'special fund' (Sondervermögen) are not subject to exit

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